Subsection 55(2) of the Income Tax Act : The Anti-Avoidance Rule, Deliberate Triggering for the CDA, and the Bill C-59 GAAR Overlay

Overview: How Subsection 55(2) Turns Tax-Free Dividends Into Capital Gains Subsection 55(2) of the Income…

Published: August 22, 2026

Last Updated: August 21, 2026

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Fighting Your CRA Reassessment at the Tax Court of Canada Through an Appeal? Does an Informal or General Procedure Apply?

Overview If you have already filed a Notice of Objection and the CRA has confirmed…

Published: August 21, 2026

Last Updated: August 21, 2026

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Repeatedly Failed to Report Income (even $500)? CRA Will Penalize You for That: Lessons from Kryski v. The King , 2026 TCC 145

Overview: Missing Income on Your Tax Return? Kryski Shows How CRA Penalties Can Arise In…

Published: August 21, 2026

Last Updated: August 21, 2026

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The Complete Playbook for Fighting CRA Tax Reassessments: When CRA Denies Your Tax Losses

Table of Contents Overview: A CRA loss denial can be challenged through a disciplined tax…

Published: August 19, 2026

Last Updated: August 19, 2026

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‘Deemed Disposition’ of all your Assets at Death: Tax Planning for Canadian Business Owners with High-Net-Worth Estates

Contents: Overview - Why Deemed Disposition at Death Requires Advance Tax Planning Deemed Disposition at…

Published: August 15, 2026

Last Updated: August 13, 2026

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Judicial Review of CRA Decisions: Challenging a CRA Refusal in Federal Court

Overview: Federal Court or Tax Court, Which One Applies? A CRA refusal is not always…

Published: August 14, 2026

Last Updated: August 13, 2026

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What Triggers a CRA Audit? Here’s the List, Compiled by a 40-year Canadian Tax Lawyer

Overview: Navigating the Risk-Based Landscape of Canadian Tax Audits The Canada Revenue Agency (CRA) employs…

Published: August 14, 2026

Last Updated: August 13, 2026

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Notice of Assessment Was Never Mailed? Federal Court of Appeal Clarifies the Taxpayer MUST FIRST PROVE NON-DELIVERY in Siam v. Canada , 2026 FCA 91

Overview: Can You Challenge a CRA Tax Reassessment If You Never Got the Original Notice?…

Published: August 13, 2026

Last Updated: August 13, 2026

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Missed CRA Email Notification After a Reassessment: Can You Still File a CRA Objection?

Contents: Overview: Missed CRA Email Notifications Can Cause Taxpayers to Lose CRA Objection Rights How…

Published: August 13, 2026

Last Updated: August 13, 2026

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